The following is a draft U.S. Department of Energy guidance document that specifies a means by 

which manufacturers of residential central air conditioning systems and air conditioning heat 

pump systems that are designed to use HCFC-22 refrigerant could comply with the applicable 

energy conservation standards. This draft guidance document represents the Department’s 

interpretation of its existing regulations and is exempt from the notice and comment 

requirements of the Administrative Procedure Act. See 5 U.S.C. § 553(b)(A). Nevertheless, 

given that the Department has not previously expressed its views on this issue, we are interested 

in receiving feedback from the public. Therefore, the Department is accepting comments and 

suggestions from the public until November 22, 2010. Comments and suggestions should be 

provided in WordPerfect, Microsoft Word, PDF, or text file format by sending an email to 

CACHP-R22-Guidance-2010-TP-0038@ee.doe.gov. Please also include the docket number: 

EERE-2010-BT-TP-0038. At the end of the comment period, this draft guidance document may 

be adopted, revised or withdrawn. 

TESTING OF R-22 SYSTEMS 

Last Day for Comments: November 22, 2010 

DOE regulations require that residential split system central air conditioners and heat 

pumps be tested using the “the evaporator coil that is likely to have the largest volume of retail 

sales with the particular model of condensing unit.” 10 C.F.R. § 430.24(m)(2). Effective January 

1, 2010, the U.S. Environmental Protection Agency (EPA) banned the sale and distribution of 

those central air conditioning systems and heat pump systems manufactured after January 1, 

2010, that are designed to use R-22 refrigerant. 74 Fed. Reg. 66450 (Dec. 15, 2009). EPA’s 

rulemaking included an exception for the manufacture and importation of replacement 

components, as long as those components are not pre-charged with R-22. Id. at 66459-66460. In 

light of EPA’s rulemaking, DOE has received numerous inquiries regarding the sale of R-22 

systems and the applicability of our regulations with respect to these types of systems. 

Specifically, manufacturers have questioned how to rate R-22 systems given that DOE’s test 

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procedure requires a determination of the coil/condensing unit combination likely to have the 

largest volume of retail sales. 

EPA’s recent rulemaking had no effect on DOE’s longstanding regulatory framework for 

the energy conservation standards for residential split system central air conditioners and heat 

pumps, which are refrigerant-blind. Currently, these systems must meet the energy conservation 

standards effective January 23, 2006, and must be certified prior to distribution in commerce. 10 

C.F.R. § 430.24(c)(2) and 10 C.F.R. § 430.62. DOE recognizes that many of the R-22 systems 

and components are part of legacy offerings that have been available over the past five years. As 

such, many of these R-22 systems were in production before January 1, 2010, and have already 

been tested and rated by their manufacturers. EPA’s rulemaking had no effect on the efficiency 

rating of these systems. These ratings continue to be valid and already should have been certified 

as compliant to DOE.1 

For manufacturers that are producing new or redesigned R-22 components or systems of 

split system air conditioners or heat pumps after January 1, 2010, DOE is clarifying the 

applicability of the test procedure. DOE’s test procedures state that split system central air 

conditioning systems and heat pumps, including systems designed to use R-22 refrigerant, should 

be tested by pairing “the evaporator coil that is likely to have the largest volume of retail sales 

with the particular model of condensing unit.” 10 C.F.R. § 430.24(m)(2). This regulatory 

provision continues to apply; however, if a manufacturer has difficulty determining the 

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 DOE is aware that the Air-Conditioning, Heating, and Refrigeration Institute (AHRI) recently dropped systems 

utilizing R-22 refrigerant from its certification programs. Because AHRI is no longer including R-22 systems in its 

certification program, manufacturers, including AHRI members participating in the AHRI certification program, 

should ensure that their R-22 systems have been certified to DOE as compliant in accordance with 10 C.F.R. § 

430.62. 

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appropriate R-22 coil that is likely to have the largest volume of retail sales due to the EPA 

prohibition on the sale of complete pre-charged systems, DOE will assume that a manufacturer 

that tests and rates a system using any R-22 evaporator coil with a capacity of 1⁄2 ton less than the 

condensing unit will have tested the system with the coil that is likely to have the largest volume 

of retail sales. DOE encourages this approach, as it will ensure that R-22 systems do not 

overstate the efficiency, while providing a simple and transparent means for manufacturers to 

continue to test and rate the products. DOE notes that manufacturers electing to use this method 

to test R-22 systems should explicitly document the methodology in their test records that they 

maintain per DOE’s regulations in 10 C.F.R. § 430.62(d) in case compliance issues arise. 

Manufacturers should note that testing performed using this method would not be valid 

for use in conjunction with any existing approved alternate rating method (ARM). Therefore, 

manufacturers would either need to apply for a new ARM using the procedures in 10 C.F.R. 

§ 430.24(m) in conjunction with new test data or each combination would have to be tested and 

rated individually. 

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